Pillar 4 / Wallet Intelligence / Bank Digital Asset Team
Crypto customer onboarding for banks.
OCC Interpretive Letter 1170 (2020) permits national banks to provide crypto custody. The OCC + FinCEN expect the same KYC, BSA, OFAC, and ongoing-monitoring rigor as for any other customer relationship. Wallet Intelligence is the per-customer attestation layer: at onboarding, transactionally, and on quarterly review. Every check is signed; every customer file is examiner-ready.
Your bank can custody crypto. The examiner expects the same systematic review you give every other high-risk customer.
The OCC and FinCEN treat crypto customers as inherently high-risk. Each customer file needs documented KYC, OFAC screening, ongoing transaction monitoring, and continuous re-screening. Wallet Intelligence is the per-customer attestation layer that produces examiner-ready evidence at onboarding and continuously thereafter.
- OCC Interpretive Letter 1170 (2020). National banks may provide crypto custody; OCC requires same KYC/BSA rigor as for traditional customers. Per-customer onboarding CREB™ supports the bank's authority + compliance posture.
- 31 CFR 1020 (bank BSA obligations). Per-customer SAR / CTR support + ongoing monitoring. JIL attestations support the BSA officer's monitoring decisions with cryptographic provenance.
- OFAC SDN + sectoral sanctions. Per-customer + per-transaction OFAC screen. Positive hits emit blocked-transaction attestation for OFAC reporting per 31 CFR 501.
- Customer-counterparty wallet attestation. When customer initiates transfer to external wallet, JIL provides counterparty wallet attestation (VASP-attested? sanctioned? mixer-adjacent?) and per-transfer signed evidence.
Crypto customer onboarding
Per-customer KYB + KYC + OFAC screen + initial wallet cluster + UBO pierce. SHA-256-sealed onboarding package court-anchored on CourtChain. Examiner-ready customer file from day 1.
Ongoing transaction monitoring
Per-transaction attestation on customer-initiated transfers (custody + withdrawal). Sanctions screen + counterparty-wallet attestation + corridor analysis + flagging.
Quarterly compliance review
Per-customer quarterly re-screen package: OFAC delta check, behavioral-pattern delta, UBO re-verify, transaction-volume vs. expected profile. Examiner-ready every quarter.
SAR / CTR support
Per-flag CREB™ supports BSA officer's SAR / CTR filing decision with reproducible methodology. Per-transaction evidence trail (not screenshots) is the BSA officer's permanent record.
Tiered per-engagement pricing
| Bank tier | Per-customer onboarding | Per-transaction | Quarterly review | OFAC re-screen |
|---|---|---|---|---|
| Community bank (under $10B assets) | $200 / customer | $0.25 / transaction | Included | Quarterly |
| Regional bank ($10B-$100B) | $150 / customer | $0.15 / transaction | Included | Monthly |
| Large bank ($100B+ assets) | $50-$100 / customer | $0.05-$0.10 / transaction | Included + custom | Real-time |
Pre-Clearance Tier-1 SLA financial backing optional. Annual contracts with committed customer counts get 12-month locked pricing. OCC + FRB exam support included in all tiers.
Want to see onboarding attestation against a sample customer file?
We bring sandbox keys + a sample customer file (anonymized) to a 30-min walkthrough. Bring your Digital Asset Team, BSA Officer, and Compliance Counsel. Production deployment typically ships 4-8 weeks after MSA.